Schedule J of the Proposed Form 5500 – Plan sponsors of group health plans take note! In July, 2016 the Department of Labor (DOL), Department of Treasury (IRS) and the Pension Benefit Guaranty Corporation (PBGC) published proposed regulations in the Federal Register regarding Proposed Revision of Annual Information Return/Reports. What is Schedule J? If the […]
Posts tagged "Disclosure"
ErisaALERT 2015-03 EBSA issues final rules and revised db plan funding notice The plan administrator of a defined benefit plan that is subject to the PBGC must provide an annual funding notice to participants and beneficiaries. Final regulations published February 2, 2015 are substantially the same as the November 2010 proposed regulations. Background The Pension […]DB, Disclosure, funding
ErisaALERT 2015-01 – The Government Accounting Office (GAO) issued at least two reports discussing rollovers. We have seen increased government focus in the rollover area. The Government Accounting Office (GAO) issued at least two reports discussing rollovers. In 2013, The GAO issued (“401(k) Plans: Labor and IRS Could Improve the Rollover Process for Participants”) focusing […]Disclosure, distribution, IRS, Rollovers
ErisaALERT 2014-09 – ACA’s shared responsibility provisions impose penalties on individuals who do not maintain minimum essential coverage (MEC) and on plan sponsors who do not offer minimum value, affordable coverage. The way the IRS will know if an individual has MEC and if an employer offers minimum value, affordable coverage is via the §6055 […]6055, 6056, ACA, compliance, Disclosure, HCR, Health Care Reform, Reporting
ErisaALERT 2013-05 discussed the statutory requirements and the proposed regulations regarding the new reporting and disclosure requirements imposed by the Affordable Care Act (ACA) relating to the individual mandate and shared responsibility. On March 10, 2014 final regulations were issued for §6055 Information Reporting of Minimal Essential Coverage (MEC) and §6056 Information Reporting by Applicable […]6055, 6056, ACA, Disclosure, Health Care Reform, Reporting
The DOL issued final 408 regulations (b)(2) on February 3, 2012 (see ErisaALERT 2012-03) which included a sample guide to initial disclosures. While not required, the DOL noted that the sample guide may be a useful tool to assist the responsible plan fiduciary. Interim final regulations which preceded the final regulations (see ErisaALERT 2010-11) requested […]408 (b) (2), 408 regulations, Disclosure, DOL, Fee Transparency, Plan Fees
Both reporting requirements have a delayed effective date of January 1, 2015 (originally effective January 1, 2014) with initial reporting and disclosure in 2016. In September, 2013, the IRS issued proposed regulations regarding ALE reporting as well as MEC reporting which modify the statutory language but leave the door open for increased reporting requirements. Refer […]ACA, Disclosure, Health Care Reform, Reporting
You received your 408(b)(2) disclosures from your covered service providers. Have you looked at them? Do you know what you are looking at? Do you know what you are supposed to do next?
In this ALERT we will focus on the plan sponsor’s responsibility with respect to the covered service provider (CSP) fee disclosures. MORE2012 archive, 408 (b) (2), Disclosure, DOL, Fee Transparency, Plan Fees
In this ALERT we will focus on the plan sponsor’s responsibility to provide fee disclosures to participants in participant directed individual account plans (except SEPs, IRAs, SIMPLEs and governmental plans) by August 31st. The ball is now in the plan sponsor’s court and it is getting close to the end of the overtime period We […]2012 archive, 404(a)(5), Disclosure, Participant disclosures
The DOL issued final 408(b)(2) regulations on February 3, 2012. These regulations provide modifications to the interim final regulations issued in 2010 (see ErisaALERT 2010-11). This ErisaALERT will discuss some of the modifications. We will provide a more extensive discussion at some point in the future. The modifications Effective date – The effective date has […]2012 archive, 408b2, covered service provider, Disclosure, DOL, fee disclosure, Fee Transparency